Interpretation ID: 1984-1.14

TYPE: INTERPRETATION-NHTSA

DATE: 02/28/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: John H. Schmidt -- Certification Supervisor, Harley-Davidson Motor Co. Inc.

TITLE: FMVSR INTERPRETATION

ATTACHMT: 6/30/76 letter from J. Womack to Toyota Motor Sales U.S.A. Inc.

TEXT:

John H. Schmidt, P.E. Certification Supervisor Harley-Davidson Motor Co., Inc. 3700 W. Juneau Avenue P.O. Box 653 Milwaukee, Wisconsin 53201

Dear Mr. Schmidt:

This responds to your February 6, 1984 letter to Roger Fairchild of this office, in which you asked whether your company may include on vehicle certification labels gross vehicle weight rating and gross axle weight rating information expressed in kilograms. The metric units would be used in addition to information expressed in pounds, with the English units appearing first on the label and the metric units following in parenthesis. Our certification regulations (49 CFR Part 567) provide that this information is to be specified in pounds.

The inclusion of metric weight ratings in addition to the English units specified in our regulation (with the English units appearing first) has previously been approved in an agency interpretation letter, a copy of which is enclosed. Therefore, your proposed certification labels are authorized under the certification regulations.

Sincerely,

Frank Berndt Chief Counsel

Enclosure (6/30/76 letter from J. Womack to Toyota omitted here)

February 6, 1984

Dear Mr. Fairchild:

The Harley-Davidson Motor Company would like to add metric equivalents to the vehicle weight ratings on its Certification Labels.

An example of the addition would be the following (sample label attached):

Present Proposed

GVWR: 1085 GVWR 1085 LB (493 KG) GAWR: Front-390 with ... GAWR F 390 LB (177 KG) with ...

GAWR: Rear-695 with ... GAWR R 695 LB (316 KG) with ...

Part 567 seems neither to permit nor to prohibit additional information on the Certification Label. Showing metric equivalents would be helpful in export of our motorcycles and would be consistent with a general objective of reducing international trade barriers.

We would appreciate a statement of concurrence from the Office of Chief Counsel.

Sincerely,

John H. Schmidt, P.E. Certification Supervisor

/pat Attachment

cc: Paul Golde, MIC Walter MacKay, MMIC